2025 (5) TMI 1793

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.... Shri. Anil Gupta - SR. DR. ORDER PER KAVITHA RAJAGOPAL, J M: This appeal has been filed by the assessee, challenging the order of the learned Commissioner of Income Tax (Appeals) ADDL/JCIT(A)-2 Noida ('ld. CIT(A)' for short) passed u/s. 250 of the Income Tax Act, 1961 ('the Act'), pertaining to the Assessment Year ('A.Y.' for short) 2017-18. 2. The solitary ground involved in this....

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....its made in co-operative banks alleged to be a commercial bank by relying on the decision of the Hon'ble Apex Court in the case of in Totgar's cooperative sale society Ltd. V. ITO [2010]322 ITR 283(SC). The ld. AO had passed the assessment order u/s. 143(3) of the Act dated 11.12.2019, determining total income at Rs. 15,19,506/-. 4. Aggrieved the assessee was in appeal before the first appe....

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....25] 171 taxmann.com 22 (Gujarat)[24-12-2024] iii. Bhagyalaxmi Co-op. Hsg. Soc. Ltd. vs. DCIT [2024] 167 taxmann.com 153(Gujrat) iv. Brahmarshi Co-op. Credit Society Ltd. vs. ACIT [2025] 170 taxmann.com 336 (Gujrat). 7. Having heard the rival submissions and perused the materials available on record. The only issue that requires adjudication is whether the assessee is entitled ....

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....eted by the Hon'ble Karnataka High Court that co-operative banks are excluded from the definition of co-operative societies by the said amendment to Section 194A(3)(v) of the Act, vide Finance Act, 2015 which on perusal is that the co-operative banks are liable to deduct TDS for the interest income on securities made by the co-operative society and not for other interest income made by the co-....